Arrowstreet Capital Fined €297,000 for Incorrect Short Position Notifications
Summary
The Dutch Authority for the Financial Markets (AFM) imposed an administrative fine of €297,000 on Arrowstreet Capital, Limited Partnership on 20 April 2026 for systematically incorrect notifications of net short positions in Just Eat Takeaway.com and Galapagos listed on Euronext Amsterdam. The firm submitted 101 incorrect notifications between July 2020 and November 2024, understating positions by tens of millions of euros in many cases, with 85 of those also violating public disclosure obligations. Arrowstreet self-reported the error, corrected it promptly, and cooperated fully with the investigation, leading to a reduced fine through the simplified settlement procedure.
“The AFM uses the notifications to monitor short positions for abuse, market distortion or systemic risks.”
Investment firms with EU short selling notification obligations should audit their position-calculation methodologies against the error Arrowstreet attributed to its calculation system. The 101 errors over four years without detection suggests a systemic gap rather than a one-off mistake. Proactive self-reporting, prompt correction, and full cooperation with the AFM investigation led to a reduced fine — a pattern regulators across EU member states may weigh similarly in enforcement outcomes.
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What changed
The AFM fined Arrowstreet Capital €297,000 for systematically notifying incorrect net short positions in Just Eat Takeaway.com and Galapagos to the regulator 101 times over four years. In 85 of those cases, the errors also violated the firm's obligation to disclose positions publicly. The violations persisted from July 2020 through November 2024, with discrepancies often in the tens of millions of euros. Investment firms and institutional investors holding reportable short positions in EU-listed securities should review their notification and disclosure calculation methodologies to ensure compliance with short selling rules under the EU Market Abuse Regulation framework.
The AFM noted that accurate short position reporting is essential for market monitoring against abuse, distortion, and systemic risk. Public disclosure of significant short positions prevents information asymmetry among investors. Firms with similar reporting obligations should ensure their systems accurately capture gross and net positions across all affected securities.
Penalties
€297,000 administrative fine
Archived snapshot
Apr 22, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Measure 22/04/26
Arrowstreet Capital fined for incorrect notifications of short positions
On 20 April 2026, the Dutch Authority for the Financial Markets (AFM) imposed an administrative fine of €297,000 on Arrowstreet Capital, Limited Partnership for the systematically incorrect notifications of its net short positions in two companies listed on Euronext Amsterdam. Arrowstreet thus violated the rules on short selling between July 2020 and November 2024.
In short
- Systematic underreporting and underdisclosure of short positions
- Accurate notifications are important for the market
- Administrative fine with simplified settlement
Systematic underreporting and underdisclosure of short positions
Arrowstreet is an institutional investment firm established in the United States. It held short positions in the companies Just Eat Takeaway.com and Galapagos, which are listed on Euronext Amsterdam. Due to an error in its calculation methodology, Arrowstreet notified incorrect net short positions to the AFM a total of 101 times. The short positions were more substantial than notified, with differences of several tens of millions of euros in many cases. In 85 of those cases, Arrowstreet violated not only its notification obligation to the AFM but also its disclosure obligation to the public.
Accurate notifications are important for the market
It is essential that net short positions are notified promptly and accurately. The AFM uses the notifications to monitor short positions for abuse, market distortion or systemic risks. Disclosure also gives market participants important information on significant individual short positions, as it reveals negative market expectations with regard to specific companies. This enables investors to take better-informed and more robust investment decisions and prevents information asymmetry.
Hanzo van Beusekom, Member of the Executive Board of the AFM: “Correct notification and disclosure of net short positions is essential to provide investors with fair and accurate information. The AFM ensures that institutions comply with these legal obligations in order to prevent risks of market abuse and market distortion.”
Administrative fine with simplified settlement
After discovering the error, Arrowstreet proactively informed the AFM of the incorrect notifications, promptly corrected them, cooperated fully with the AFM’s investigation and took measures to prevent a recurrence. This approach led the AFM to reduce the fine. Arrowstreet accepted the fine and the case was settled through the simplified procedure. The case is therefore closed.
More information
In Dutch: decision Arrowstreet Capital (pdf, 430 kB)
Contact for this article
Charlene Zikmund charlene.zikmund@afm.nl
+31 6 29 42 08 87
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